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United States securities and exchange commission logo
January 18, 2024
Ryan Melsert
Chief Executive Officer
American Battery Technology Company
100 Washington Street, Suite 100
Reno, NV 89503
Re:American Battery Technology Company
Registration Statement on Form S-3
Filed December 29, 2023
File No. 333-276329
Dear Ryan Melsert:
            We have conducted a limited review of your registration statement and have the
following comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form S-3
Incorporation By Reference
Form 8-K Filed December 21, 2023
Item 9.01 Financial Statements and Exhibits
Exhibit 99.1, page 1
1.We note that your press release includes the economic results of a technical report
summary that is based solely on inferred resources.  If providing an economic analysis in
an initial assessment, inferred resources may be included in the economic analysis,
provided the information under Item 1302(d)(4)(ii) of Regulation S-K is also provided.
This is required disclosure in the initial assessment that forms part of the economic
analysis, and therefore should accompany the economic results in other disclosures, such
as your press release.

 FirstName LastNameRyan Melsert
 Comapany NameAmerican Battery Technology Company
 January 18, 2024 Page 2
 FirstName LastName
Ryan Melsert
American Battery Technology Company
January 18, 2024
Page 2
The information required includes a statement that the assessment is preliminary in nature,
it includes inferred resources that are considered too speculative geologically to have
modifying factors applied to them that would enable them to be categorized as mineral
reserves, and there is no certainty that this economic assessment will be realized; the
percentage of mineral resources used in the cash flow analysis that are classified as
inferred should be disclosed; and the results of the economic analysis without inferred
resources should be disclosed.

The information required under Item 1302(d)(4)(ii) of Regulation S-K should be provided
with equal prominence to the rest of the results, in context and format.  Please revise your
press release to include this information.
2.We note that your press release states that the mine life of the project is over 400 years,
however the technical report summary contemplates a 50 year mine life.  Please advise.
Incorporation By Reference
Form 8-K/A Filed December 22, 2023
Item 9.01 Financial Statements and Exhibits
Exhibit 99.6, page 1
3.Please obtain a revised technical report summary that includes the information required
under Item 1302(d)(4)(ii) of Regulation S-K.  In order to satisfy the equal prominence
requirement, the cautionary language and the results of the economic analysis should be
presented with and without inferred resources throughout the entirety of the technical
report summary, including the introduction and conclusion, along with any other required
disclosure.
4.We note that the technical report summary contemplates the production of lithium
hydroxide monohydrate (LHM), including a production capacity of 33,000 tons of lithium
hydroxide monohydrate in Section 14.1 and production of 1,612k tons LHM on page on
page 85; however certain tables include lithium hydroxide (LiOH), such as Table 19.1.
Please advise and if necessary obtain a revised technical report summary.
5.The capital and operating costs in an initial assessment must have an accuracy of at least
plus or minus 50%.  Please obtain a revised technical report summary that states the
accuracy of the operating and capital costs as required by Item 601(b)(96)(iii)(B)(18)(i) of
Regulation S-K, or tell us where this information is located in the technical report
summary.
6.We are unable to read Table 19-2 Initial Assessment Cash-Flow due to the size of the font.
Please obtain a revised technical report summary that presents this table in a legible
manner, for example a larger font size or multiple pages.

 FirstName LastNameRyan Melsert
 Comapany NameAmerican Battery Technology Company
 January 18, 2024 Page 3
 FirstName LastName
Ryan Melsert
American Battery Technology Company
January 18, 2024
Page 3
7.We note that the technical report includes mineral resources on adjacent properties
beginning on page 91.  Resources prepared under another jurisdiction cannot be
substituted for SK 1300 compliant mineral resources.  If necessary obtain a technical
report summary that does not include quantities of mineral resources prepared under
another jurisdiction that are not SK 1300 compliant.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            For engineering related questions please contact John Coleman at 202-551-3610.  Please
contact Michael Purcell at 202-551-5351 or Daniel Morris at 202-551-3314 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Amy Bowler